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Population deviations among districts may be sufficiently large to require justification but nonetheless be justifiable and legally sustainable. Minor deviations from mathematical equality among state legislative districts are insufficient to make out a prima facie case of invidious discrimination under the Fourteenth Amendment so as to require justification by the state.
Under a reapportionment plan for the Connecticut state legislature, population variations among the state's 36 Senate districts and 151 House of Representatives districts were such that the population of the smallest Senate district (83,441) was approximately 1.81% smaller than that of the largest Senate district (84,973), and the population of the smallest House of Representatives district (19,297) was approximately 7.83% smaller than that of the largest House district (20,870). The plan was based on a "political fairness" principle which was designed to reflect the relative strength of the major political parties by creating a certain number of "safe" districts for each party and a certain number of "swing" districts. The plan was challenged in the United States District Court for the District of Connecticut. A three-judge District Court was convened and held that the population variations among the districts were not justified by any sufficient state interest and violated the equal protection clause, and that the policy of partisan political structuring was not a legitimate reason for violating the requirement of numerical equality in districting.
Are minor deviations from mathematical equality among state legislative districts sufficient to make out a prima facie case of invidious discrimination under the equal protection clause?
The court indicated that state reapportionment was the task of local legislatures and that their work should not be invalidated under the Equal Protection Clause when only minor population variations among districts were proven. The court found that the allegations and proof of population deviations among Connecticut's districts failed in size and quality to amount to an invidious discrimination under the Fourteenth Amendment that invalidated the plan. The court also found that a state reapportionment plan, otherwise within tolerable population limits, was not invalidated because it recognized the political strength of a group or party and, through districting, provided a rough sort of proportional representation in its legislative halls.